Frequently Asked Questions

Through our discussions with MLTSS plans, we learned that plans—particularly those operating in multiple states—can ease the burden of data collection by mapping their existing assessment and care plan tools to the standardized data elements and terminology in these measures, which would make it easier to abstract data and standardize the data collection process. It is also important for MLTSS plan managers to train staff to document assessment and care plan elements consistently, as well as train individuals responsible for collecting data on how to interpret each of the elements specified in each measure. Plans can also ease the burden of data collection by ensuring data from multiple sources are consolidated into a central data system.

FAQ ID:89041

Managed Long Term Services and Supports (MLTSS) plan managers should provide training on proper documentation practices to care managers and other delegated staff. States and MLTSS plans could consider including data field entry options to remind care managers to record all results of the assessment, even if findings are negative, that is, the member does not have a problem or need assistance or services. For example, states and plans could include a question in the member’s record that requires the care manager to document both whether an assessment was performed and whether a problem was identified, along with another required field to include the details of the problem if there was a problem identified.

FAQ ID:89046

If MLTSS plans report measure rates directly to the state, the state should conduct an independent review of a sample of members included in the reported measures, for example, by the External Quality Review Organization or state-employed abstractors.

FAQ ID:89051

Four of the eight measures (LTSS Comprehensive Assessment and Update, LTSS Comprehensive Care Plan and Update, LTSS Shared Care Plan with Primary Care Practitioner (PCP), and Screening, Risk Assessment, and Plan of Care to Prevent Future Falls) apply to all members receiving a LTSS benefit through the MLTSS plan regardless of whether the MLTSS plan covers their medical care benefit. The remaining four measures (LTSS Reassessment/Care Plan Update after Inpatient Discharge, LTSS Admission to an Institution from the Community, LTSS Minimizing Institutional Length of Stay, and LTSS Successful Transition after Long-Term Institutional Stay) require members to receive a medical benefit through the MLTSS plan to be eligible for the measures (that is, the MLTSS plan is the primary payer for the medical care services, such as inpatient hospital stays and post-acute care). These four measures rely on inpatient claims (that is, hospital and skilled nursing facility), which may not be available to the MLTSS plan if the plan is not the primary payer for the service. Although members whose medical care benefits are not covered through the MLTSS plan are not eligible for the measure, we recommend MLTSS plans track members’ admissions or discharges from inpatient facilities where possible.

If MLTSS plans can obtain timely, complete, and accurate inpatient claims data for their members, then a state may choose to deviate from the measure specifications to require that MLTSS plans not providing medical benefits report these four measures.

FAQ ID:89056

The measures are intended for any MLTSS plan that covers Medicaid LTSS benefits. Federal regulations pertaining to 1915(c) waivers require person-centered service plans,¹ but states can decide whether to require MLTSS plans participating in a state program operating under 1915(c) authority report these measures, and if they do, states can specify which types of plans and eligible members to which the measures apply.

¹"In accordance with 42 CFR §441.301 (b)(1)(i), all waiver services must be furnished pursuant to a written service plan that is developed for each waiver participant." (1915c waiver application, Instructions, Technical Guide and Review Criteria (PDF, 2.29 MB), Appendix D-1: Service Plan Development, CMCS, DEHPG, November 2014.

FAQ ID:89061

The Precertification Pilot was an experiment conducted from October 2017-March 2018 designed to streamline certification and attract new vendors. Unfortunately, the pilot was found to be unscalable across Medicaid. However, key learnings from the pilot will be incorporated into current processes and future experiments around vendor engagement, certification, scalability, and sustainability. The goals the Centers from Medicare & Medicaid Services (CMS) identified at the beginning of the Precertification Pilot process remain the same: reduce the level of effort of certification; shorten the certification timeline; promote modularity and interoperability; reduce risk of system failure; and attract new vendors to the Medicaid IT market. Contact CMS with your ideas for experiments to achieve those goals at MES@cms.hhs.gov.

FAQ ID:95151

As contained in the MECT standard RFP/contract language required by CMS, CMS does not cover activities that the state may require of the IV&V contractor during ongoing O&M. However, as Medicaid is moving away from monolithic single applications, it is expected that states will continuously update and replace modules in their enterprise. Therefore, IV&V should always have a role to ensure successful integration and testing.

FAQ ID:94881

If an organization is performing another role (such as systems integrator, PMO, quality assurance, etc.) on the MMIS or E&E project, it may not perform the IV&V function on the same project. A state may contract the same vendor to perform the IV&V role for both its E&E and MMIS projects.

FAQ ID:94886

To reduce potential conflict of interest, CMS is ensuring that states are arranging IV&V services through contracts that should be owned outside of the agency that owns the MMIS or E&E project. The oversight organization for the IV&V contractor should not be involved in oversight of the development effort, a stakeholder in the business implementation, or the DDI contractor. The IV&V contract monitor should be aware of system development problem solving, reporting, and contractor management. This contract oversight provides true independence between the IV&V contractor and system development teams. This requirement is consistent with other HHS agencies' practices and industry best practices.

FAQ ID:94891

CMS encourages states to reuse modular solutions as much as possible. If a state can reuse a modular solution from another state with minimal changes or customization, CMS will work with the state to streamline the certification process as much as possible to leverage knowledge of the reused solution. However, CMS will still require a certification decision for each state implementation of reused solutions to ensure compliance with federal regulations.

FAQ ID:94896